Studivant v. State

847 S.E.2d 588, 309 Ga. 650
CourtSupreme Court of Georgia
DecidedAugust 24, 2020
DocketS20A1024
StatusPublished

This text of 847 S.E.2d 588 (Studivant v. State) is published on Counsel Stack Legal Research, covering Supreme Court of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Studivant v. State, 847 S.E.2d 588, 309 Ga. 650 (Ga. 2020).

Opinion

FINAL COPY 309 Ga. 650

S20A1024. STUDIVANT v. THE STATE.

BLACKWELL, Justice.

Marquis Lejon Studivant was tried by a Hall County jury and

convicted of murder and other crimes in connection with the fatal

shooting of Dennis Gayton. Studivant appeals, claiming that the

evidence is insufficient to sustain his convictions, that the trial court

erred when it denied his motion to suppress evidence that was

collected from a vehicle he was driving around the time of his arrest,

and that he was denied the effective assistance of counsel. Upon our

review of the record and briefs, we see no error and affirm.1

1 Gayton was shot in April 2017. A Hall County grand jury indicted Studivant and Tadrick Osborne in November 2017, charging each of them with murder during the commission of a felony and conspiracy to sell synthetic marijuana. Studivant alone was charged with two additional counts of felony murder, attempted armed robbery, two counts of aggravated assault, cruelty to children, the unlawful possession of a firearm during the commission of a crime, and the unlawful possession of a firearm by a convicted felon. Osborne pleaded guilty to lesser charges and testified in August 2018 at Studivant’s trial. The jury found Studivant guilty of all charges, and the trial court sentenced him to imprisonment for life for felony murder predicated on conspiracy to sell synthetic marijuana, a concurrent term of imprisonment for 1. Viewed in the light most favorable to the verdict, the

evidence presented at trial shows that Studivant and Tadrick

Osborne were drug dealers in the Newtown neighborhood of

Gainesville. On the evening of April 4, 2017, Osborne had two bags

of synthetic marijuana, and he and Studivant agreed that Osborne

would sell one bag to a “dude named Mel” and that they would “go

somewhere and sell [the other bag] together.” Around 9:30 or 10:00

p.m., as Studivant and Osborne walked toward the location at which

they planned to meet “Mel,” Gayton drove up to them in his truck —

accompanied by his 15-year-old son — and said that he wanted to

buy drugs for $40. Studivant approached Gayton’s parked truck, and

when Gayton pulled out approximately $70, Studivant demanded all

twenty years for an aggravated assault upon Gayton’s son, and a consecutive term of imprisonment for five years for the unlawful possession of a firearm during the commission of a crime. The other firearm possession count was nolle prossed, the other felony murder counts were vacated by operation of law, and the trial court merged the remaining counts for sentencing purposes. (These mergers are not challenged on appeal, and we, therefore, decide nothing about them. See Dixon v. State, 302 Ga. 691, 698 (4) (808 SE2d 696) (2017).) Studivant timely filed a motion for new trial in August 2018, which he amended in April 2019. The trial court denied the motion in July 2019, Studivant filed a motion for an out-of-time appeal in December 2019, the trial court allowed an out-of-time appeal in January 2020, and Studivant timely filed a notice of appeal. The case was docketed in this Court for the April 2020 term and submitted for decision on the briefs. the money. When Gayton refused, Studivant pointed a handgun at

Gayton and his son, and Studivant fatally shot Gayton as Gayton

attempted to wrestle the gun from him. A man who knew Studivant

heard the gunshots and saw Studivant and Osborne flee the scene

together. Studivant later confessed to his ex-boyfriend that he killed

Gayton, although he claimed that he did so in self-defense. Gayton’s

son identified Studivant as the man who killed his father.

Studivant claims that the evidence is insufficient to sustain his

convictions because there was no evidence that he and Osborne

conspired to sell synthetic marijuana and because Osborne’s

testimony was not corroborated, as required by OCGA § 24-14-8.

Both of these claims, however, lack merit. The State may prove a

conspiracy “by showing that two or more persons tacitly came to a

mutual understanding to pursue a criminal objective,” and “[w]here

there is no evidence of an express agreement, an inference that two

or more people tacitly came to a mutual understanding to commit a

crime can be drawn from the nature of the acts done, the relation of

the parties, the interest of the alleged conspirators, and other circumstances.” Chavers v. State, 304 Ga. 887, 891-892 (2) (823

SE2d 283) (2019) (citations and punctuation omitted). Here, there

was evidence that Studivant and Osborne were in the business of

selling synthetic marijuana together (with Osborne acting as

Studivant’s “boss”), and Osborne testified that he and Studivant

were walking in Newtown on the evening of April 4, 2017, with the

understanding that Osborne would sell one of the bags of synthetic

marijuana to “Mel” and that Studivant and Osborne would sell the

other bag “together.” Studivant and Osborne were observed together

by multiple witnesses that evening (including one who saw them

fleeing from the crime scene together), and only Studivant was

described as carrying a bag (which the jury could infer contained the

drugs that the men had conspired to sell). The evidence is sufficient

under the Due Process Clause of the Fourteenth Amendment of the

United States Constitution to authorize a rational trier of fact to find

beyond a reasonable doubt that Studivant was guilty of felony

murder predicated on a conspiracy to sell synthetic marijuana as

well as the other crimes of which he was convicted. See Jackson v. Virginia, 443 U.S. 307, 319 (III) (B) (99 SCt 2781, 61 LE2d 560)

(1979).

As to Studivant’s claim under OCGA § 24-14-8 that the State

failed to corroborate Osborne’s testimony, the record shows that

Studivant was identified by Gayton’s son as the man who fatally

shot his father, he was identified by an acquaintance as he fled the

crime scene, and he confessed to his ex-boyfriend that he had shot

Gayton. The jury was authorized to find that such evidence

sufficiently corroborated Osborne’s testimony. See Crawford v.

State, 294 Ga. 898, 901 (1) (757 SE2d 102) (2014) (“Once the State

adduces [corroborating] evidence, it is peculiarly a matter for the

jury to determine whether the evidence sufficiently corroborates the

accomplice’s testimony and warrants a conviction.” (citation and

punctuation omitted)).

2. Studivant contends that the trial court erred when it denied

a motion to suppress evidence that was collected pursuant to a

search warrant from a vehicle that Studivant was driving shortly

before his arrest. In September 2017 — after a warrant was issued for his arrest — officers learned that Studivant was driving a

Chevrolet Tahoe in Newtown. Officers found the Tahoe, and

Studivant briefly led the officers on a chase before he crashed the

Tahoe, fled on foot, and ultimately was captured and arrested. Soon

thereafter, an investigator secured a search warrant for the crashed

Tahoe, which resulted in the discovery of a rose-colored iPhone, the

data on which was later searched pursuant to a second warrant.

Studivant filed a motion to suppress evidence collected from the

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Jackson v. Virginia
443 U.S. 307 (Supreme Court, 1979)
Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Kimmelman v. Morrison
477 U.S. 365 (Supreme Court, 1986)
Lawler v. State
576 S.E.2d 841 (Supreme Court of Georgia, 2003)
Crawford v. State
757 S.E.2d 102 (Supreme Court of Georgia, 2014)
Shockley v. State
777 S.E.2d 245 (Supreme Court of Georgia, 2015)
Dixon v. State
808 S.E.2d 696 (Supreme Court of Georgia, 2017)
Chavers v. State
823 S.E.2d 283 (Supreme Court of Georgia, 2019)

Cite This Page — Counsel Stack

Bluebook (online)
847 S.E.2d 588, 309 Ga. 650, Counsel Stack Legal Research, https://law.counselstack.com/opinion/studivant-v-state-ga-2020.